Victor Commodity Consulting

Home Terms and Conditions Privacy Policy

Victor Commodity Consulting (VCC), a division of Victor Asset Management, L.L.C. (VAM), considers privacy to be fundamental to our relationship with our customers. VCC adheres to the following VAM Privacy Policy.

Per Commodity Futures Trading Commission (“CFTC”) Regulation 160 – Privacy
of Consumer Financial Information, financial firms such as Victor Asset 
Management, L.L.C. (“VAM”) are required to provide privacy notices to their
Customers both prior to opening an account and annually thereafter.  We at VAM
consider privacy to be fundamental to our relationship with our Customers and
we are committed to maintaining the confidentiality, integrity and security of
our Customers’ non-public information.  Accordingly, we have developed internal
polices to protect Customer information.  The following privacy disclosures
describe the standards VAM follows for the collection, use, and protection of VAM
Customers’ non-public personal information.  The VAM Compliance Officer is
responsible for ensuring the privacy of Customer records and information in
accordance with the VAM Privacy Policy.

Information VAM Collects.

VAM collects non-public information about Customers from the following sources:
(i) information on account documents and other forms, which may include a
Customer’s name, address, tax identification number, age, marital state, number
of dependents, assets, debts, income, employment history, beneficiary
information, and personal bank account information; (ii) information from a
Customer’s transactions with VAM, such as account trading history and/or account
balances; and (iii) correspondence, whether written, telephonic or electronic, 
between a Customer, VAM and/or any service providers for a Customer’s account.

Information VAM Protects.

VAM treats non-public personal information in a confidential manner and limits
access to the non-public personal information it has about Customers to its
employees, affiliates, and financial service providers who have an appropriate
reason to access it, and to third parties to which a Customer has requested such 
disclosure.  VAM endeavors to maintain appropriate safeguards such as physical, 
electronic and procedural safeguards to protect such information and requires 
third parties with whom it shares such information to maintain safeguards as 
well.  Non-public personal information may be maintained in locked filing 
cabinets, on password-protected computers with internet security software
and/or backed up on a secured third-party server provided by a reputable online
data storage/data security firm.  Access to non-public personal information is 
restricted to VAM personnel identified by the VAM Compliance Officer as 
appropriate authorized VAM personnel.

Information VAM Discloses.

VAM does not disclose any non-public personal information that it collects to 
unaffiliated third parties except to the extent necessary for a financial service
provider, such as an FCM or over-the-counter Forex Dealer, to process the
Customer’s account(s) and as expressly permitted by a Customer or by law. VAM
treats non-public personal information concerning prospective Customers and
former Customers in the same way it treats such information about current Customers.

Recording of Telephone Conversations.
  
For the protection of both the Customer and VAM, and as a way of correcting 
misunderstandings, VAM and/or any individual or entity legally authorized to act 
on behalf of VAM may monitor and/or record, without restrictions, any and/or all 
telephone conversations between VAM or any individual or entity legally 
authorized to act on behalf of VAM and any Customer, including prospective and 
former Customers, or any individual or entity acting on behalf of a Customer.  
Recorded telephone conversations are saved on a protected computer hard drive 
and are backed up periodically.

Services: Risk Management/Hedging Black Box/Algorithmic Trading Asset Management Commercial/Retail Brokerage

700 Louisiana, Suite 2435, Houston, Texas 77002 U.S.A. Phone: +1 713 222 7575 Fax: +1 713 222 7576 Email: info@victorassetmanagement.com